evidence advisors, llc 10004 johns road boerne, tx 78006 ... · this brochure provides information...

Evidence Advisors ADV Part 2A April 2016 1 of 28

Evidence Advisors, LLC

10004 Johns Road

Boerne, TX 78006

Phone: (210) 710-0691

www.evidenceadvisors.com

April 15th, 2016

This Brochure provides information about the qualifications and business practices of Evidence

Advisors, LLC. If you have any questions about the contents of this Brochure, please contact us

at (210) 710-0691 or via email at [email protected]. The information in this

Brochure has not been approved or verified by the United States Securities and Exchange

Commission (“SEC”) or by any state securities authority.

Evidence Advisors, LLC (“Evidence Advisors Investment Management”) is a Registered

Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or

training. The oral and written communications of an Adviser provide you with information that

you may use to determine whether to hire or retain them.

Additional information about Evidence Advisors Investment Management is also available via

the SEC’s website www.adviserinfo.sec.gov. You can search this site by using a unique

identifying number, known as a CRD number. The CRD number for Evidence Advisors

Investment Management is 282234. The SEC’s web site also provides information about any

persons affiliated with Evidence Advisors Investment Management who are registered, or are

required to be registered, as Investment Adviser Representatives of Evidence Advisors

Investment Management.

Evidence Advisors ADV Part 2A April 2016 of 28

© 2010 – 2016 Red Oak Compliance Solutions LLC

Item 2 – Material Changes

This is a new adviser.

This Brochure, dated April 15, 2016, is a new document that describes the adviser’s business.

In the future, this section of the Brochure will discuss only the specific material changes that were made to the Brochure and will provide you with a summary of all material changes that have occurred since the last filing of this Brochure. This section will also identify the date of our last annual Brochure update.

We will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year end which is December 31st. We will provide other ongoing disclosure information about material changes as they occur. We will also provide you with information on how to obtain the complete brochure. Currently, our Brochure may be requested at any time, without charge, by contacting Wyatt Moerdyk at (210) 710-0691.



Item 3 – Table of Contents

Item 1 – Cover Page ...........................................................................................................................1

Item 2 – Material Changes ..................................................................................................................2

Item 3 – Table of Contents .................................................................................................................3

Item 4 – Advisory Business Introduction .............................................................................................4

Item 5 – Fees and Compensation ........................................................................................................9

Item 6 – Performance Based Fee and Side by Side Management ....................................................... 12

Item 7 – Types of Client(s) ................................................................................................................ 13

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 13

Item 9 – Disciplinary Information ..................................................................................................... 18

Item 10 – Other Financial Industry Activities and Affiliations ............................................................. 18

Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading ................ 19

Item 12 – Brokerage Practices .......................................................................................................... 21

Item 13 – Review of Accounts ........................................................................................................... 23

Item 14 – Client Referrals and Other Compensation .......................................................................... 23

Item 15 – Custody ............................................................................................................................ 23

Item 16 – Investment Discretion ....................................................................................................... 24

Item 17 – Voting Client Securities ..................................................................................................... 25

Item 18 – Financial Information ........................................................................................................ 25

Item 19 – Requirements for State Registered Advisers ...................................................................... 25

ADV Part 2B Brochure Supplement – Wyatt Moerdyk, AIF®................................................................ 26



Item 4 – Advisory Business Introduction

Our Advisory Business Evidence Advisors, LLC (“Evidence Advisors Investment Management”, “us”, “we”, “our”) was founded in November 2015 by Wyatt Moerdyk who serves as Chief Compliance Officer and Managing Member.

Evidence Advisors Investment Management is a Registered Investment Adviser (“Adviser”) and a consultant to trustees, investment committee members, institutional investors, any other fiduciary involved in managing the investment selection process for a qualified retirement plan and individual participants.

We also provide consulting and advisory services for employer-sponsored retirement plans in accordance with the Employee Retirement Income Security Act (“ERISA”). The services provided are ERISA 3(21) and 3(38) fiduciary services. When delivering ERISA services, we will perform these services for the retirement plan as a fiduciary under ERISA Section 3(21)(A)(ii) will act in good faith and with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. These services are provided on a discretionary basis for ERISA 3(38) services and a non-discretionary basis for ERISA 3(21) services.

We also provide asset management and financial planning services to individuals, high net worth individuals, trusts, estates, corporate pension and profit-sharing plans, charitable organizations, foundations, endowments, corporations and small businesses.

We provide investment advice through Investment Adviser Representatives (“IAR”) associated with us. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on our behalf. In addition, all IARs are required to have a college degree, professional designation, or equivalent professional experience.

We are committed to the precept that by placing the client’s interests first, we will add value to the asset management process and earn the client’s trust and respect. We value long term relationships with our clients whom we regard as strategic partners in our business.

Services At Evidence Advisors, LLC we provide our clients with discretionary investment management services. Our focus is primarily on building passively managed or index fund portfolios that are customized to meet our clients’ level of risk. Our investment strategies are strongly based upon the academic research of leaders in the field of finance. Evidence Advisors, LLC takes an “evidence based” approach to investment management. We believe that there is a significant body of scientific evidence that can be applied to practical investing. Evidence Advisors, LLC portfolio construction is based on research into financial markets, asset pricing, dimensions of higher expected returns, and other principals of investing supported by academia.

We do not participate in wrap fee programs.



Asset Management Asset management is the professional management of securities (stocks, bonds and other securities) in order to meet your specified investment goals. With an Asset Management Account, you engage us to assist you in developing a personalized asset allocation program and customized portfolio designed to meet your unique investment objectives. The investments in the portfolio account may include mutual funds, stocks, bonds, equity options, futures, etc.

We will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other pertinent information.

Based on the information you share with us, we will analyze your situation and recommend an appropriate asset allocation or investment strategy. Our recommendations and ongoing management are based upon your investment goals and objectives, risk tolerance, and the investment portfolio you have selected. We will monitor the account, trade as necessary, and communicate regularly with you. Your circumstances shall be monitored in quarterly and annual account reviews. These reviews will be conducted in person, by telephone conference, and/or via a written inquiry/questionnaire. We will work with you on an ongoing basis to evaluate your asset allocation as well as rebalance your portfolio to keep it in line with your goals as necessary. We will be reasonably available to help you with questions about your account.

We will:

• Review your present financial situation

• Monitor and track assets under management

• Provide portfolio statements, periodic rate of return reports, asset allocation statement, rebalanced statements as needed

• Advise on asset selection

• Determine market divisions through asset allocation models

• Provide research and information on performance and fund management changes

• Build a risk management profile for you

• Assist you in setting and monitoring goals and objectives

• Provide personal consultations as necessary upon your request or as needed.

You are obligated to notify us promptly when your financial situation, goals, objectives, or needs change.

You shall have the ability to impose reasonable restrictions on the management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These restrictions may be a specific company security, industry sector, asset class, or any other restriction you request.

Under certain conditions, securities from outside accounts may be transferred into your advisory account; however, we may recommend that you sell any security if we believe that it is not suitable for the current



recommended investment strategy. You are responsible for any taxable events in these instances. Certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is not indicative of future results.

We can also work with you, in a consulting capacity, to create an Investment Policy Statement (IPS) that will serve as the roadmap to guide your wealth management program. Your IPS will incorporate many different aspects of your financial status into an overall plan designed to meet your goals and objectives. We will create a formal IPS and deliver it to you upon completion.

If you decide to implement our recommendations, we will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, at an independent custodian, and not with us. We recommend using Charles Schwab & Co. (“Schwab”); however, you may use any custodian you wish.

You will enter into a separate custodial agreement with the custodian which authorizes the custodian to take instructions from us regarding all investment decisions for your account. You will be notified of any purchases or sales through trade confirmations and statements that are provided by the custodian. These statements list the total value of the account, itemize all transaction activity, and list the types, amounts, and total value of securities held. You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations.

We may also provide you with a quarterly performance statement starting at the end of the first full calendar quarter after signing the Advisory Agreement. These statements give you additional feedback regarding performance, educate you about our long-term investment philosophy, and describe any changes in current strategy and allocation along with the reasons for making these changes.

We manage assets on a discretionary basis, which means you have given us the authority to determine the following with/without your consent:

• Securities to be bought or sold for your account

• Amount of securities to be bought or sold for your account

• Broker-dealer to be used for a purchase or sale of securities for your account

Trading may be required to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after a request for a withdrawal that requires liquidation of a position. Additionally, your account may be rebalanced or reallocated periodically in order to reestablish the targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur on the schedule we have determined together. You will be responsible for any and all tax consequences resulting from any rebalancing or reallocation of the account. We are not tax professionals and do not give tax advice. However, we will work with your tax professionals to assist you with tax planning.

We are available during normal business hours either by telephone, fax, email, or in person by appointment to answer your questions.



Third Party Money Managers We may determine that opening an account with a professional third party money manager is in your best interests. We have contracts with CLS and Betterment Institutional.

The money managers selected under these programs will have discretion to determine the securities they buy and sell within the account. Due to the nature of these programs, each of the independent money managers is obligated to provide you with a separate disclosure document. You should carefully review this document for important and specific program details, including pricing.

Under these programs, we may:

• Assist in the identification of investment objectives

• Assist in the selection of appropriate money managers and review performance and progress

• Recommend the hiring and firing of money managers utilized by you.

You should read the ADV Part 2 disclosure document of the money manager you select for complete details on the charges and fees you will incur.

Financial Planning/Consulting We provide services such as comprehensive financial planning and financial consulting. Fee based financial planning is a comprehensive relationship which incorporates many different aspects of your financial status into an overall plan that meets your goals and objectives. The financial planning relationship consists of face-to-face meetings and ad hoc meetings with you and/or your other advisors (attorneys, accountants, etc.) as necessary.

In performing financial planning services, we typically examine and analyze your overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing your current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement with you.

It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant or other professionals.

If you engage us to perform these services, you will receive a written agreement detailing the services, fees, terms and conditions of the relationship. You will also receive this Brochure. You are under no obligation to implement recommendations through us. You may implement your financial plan through any financial organization of your choice.

We obtain information from a wide variety of publicly available sources. We do not have any inside private information about any investments that are recommended. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Choosing which advice to follow is your decision.



Qualified Retirement Plan Advisory Services Plan sponsors are increasingly looking for an investment advisor to help shoulder fiduciary responsibilities. Under a 3(21) fiduciary advisory arrangement Evidence Advisors Investment Management make recommendations of investments to plan sponsors, monitor the selected investments to help ensure performance, and provide guidance throughout the fiduciary process. As an ERISA Section 3(21) fiduciary, Evidence Advisors Investment Management does not have authority to make and implement fiduciary decisions for the plan. Our recommendations relieve plan sponsors of some of the liability associated with their investment decisions, when the decisions are based on our advice. The plan sponsor is responsible for the selection and monitoring of the 3(21) investment manager and implementation of any of the 3(21) investment manager’s investment recommendations, and assumes responsibility and liability for any overriding decisions made by the plan sponsor. The plan sponsor will have the opportunity to meet with us periodically to review the plan strategies.

Plan Sponsors or trustees may also elect to appoint Evidence Advisors Investment Management as a 3(38) fiduciary investment manager. Under this arrangement, Evidence Advisors Investment Management accepts discretion over plan assets and assumes full responsibility and liability for fiduciary functions concerning decisions related to the plan assets. As a 3(38) plan fiduciary, we will conduct research to determine appropriate investment selections and allocations and to project potential ranges of returns and market values over various time periods and using various cash flows.

The data used to determine the investment options is based on estimated, forward-looking performance of various asset classes and subclasses to create our forward looking capital markets assumptions (e.g., expected return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the asset classes and the indexes that correspond to these asset classes may not be representative of actual future performance. Actual results could differ, based on various factors including the expenses associated with the management of the portfolio, the portfolio’s securities versus the securities comprising the various indexes and general market conditions. Before a specific investment is selected, other factors such as economic trends, which may influence the choice of investments and risk tolerance, are considered. We have the responsibility and authority to determine the investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which may be retained or replaced.

We also encourage you to consult with your other professional advisors since we do not provide legal advice that may affect asset classes or allocations used in the modeling. We will apply guidelines you supply, as directed, however, compliance with these restrictions or guidelines, is your responsibility.

We will assist you in creating a written investment policy statement (“IPS”) to document the plan’s investment goals and objectives as well as certain policies governing the investment of assets. The IPS also identifies an investment strategy that seeks to attain the plan’s goals.

We will assist with the establishment, execution, and interpretation of the Investment Policy Statement. The Investment Policy Statement serves as a guide to assist in effectively supervising, monitoring, and evaluating the investment of the plan’s assets. We will prepare a draft of the IPS based upon information furnished by you and your firm designed to profile various factors for the account such as investment objectives, risk tolerances, projected cash flow, and demographics of your retirement plan participants.



It is your responsibility to provide all necessary information for the preparation of the IPS, particularly any limitations imposed by law or otherwise. This draft IPS is then submitted to you for review and approval. We recommend that your professional advisors, such as an attorney, actuary, and/or accountant, also review the IPS.

Upon your final approval, it is our responsibility to adhere to the IPS while managing the retirement program. We encourage you to review accounts periodically to verify our compliance with the IPS.

The Investment Policy Statement will be reviewed at least annually to determine whether stated investment objectives are still relevant and the continued feasibility of achieving those objectives. However, the Investment Policy Statement is not expected to vary much from year to year and the IPS will not be updated to account for short term changes in market conditions or the economic environment.

We will also monitor the current managed investment line up including the investment’s performance compared to an applicable benchmark. If we determine that a fund no longer meets our criteria, we will select possible alternatives and assist in the selection of a replacement investment.

If you decide to implement any of our recommendations, we will help you open a custodial account(s) for the plan. The funds in your account will be held in a separate account, in the plan’s name, at an independent custodian, not with us. We use Matrix Capital a MG Trust Company as the custodian for the plan. The custodian will effect transactions, deliver securities, make payments, etc.

We may conduct plan participant meetings when a change is made either to the structure of the plan or if the investment lineup changes as a result of our decisions. We will detail the changes being made, how it affects the current participants, review the current investment opportunities, how participants may make changes to their investment selections, and will answer any questions a participant may have. We will review with the participants how to select the investments in their online account.

Assets Under Management As of February 2016, we do not have any asset under management nor do we have accounts for which we provide asset management services. We are a new adviser in 2016.

Item 5 – Fees and Compensation

We provide qualified retirement plan advisory services, asset management, and financial planning services for a fee.

You can terminate the relationship without penalty within the first five (5) days after the signing of this agreement. After the initial five days, either party may terminate the relationship with a thirty (30) day written notice. Upon termination of any account, any prepaid fees that are in excess of the services performed will be promptly refunded to you. Any fees that are due, but have not been paid, will be billed to you and are due immediately.



Asset Management Fee Schedule We charge a negotiable fee of up to 2.00% annually based upon the value of your account under management and/or certain other circumstances. We do not charge fees based on a tiered fee schedule. Multiple accounts of immediately-related family members, at the same mailing address, may be considered one consolidated account for billing purposes. Fees are charged quarterly in arrears. Payments are due and will be assessed on the last day of each quarter, based on the ending balance of the account under management for the ending quarter.

No increase in the annual fee shall be effective without prior written notification and approval from you. We believe our advisory fee is reasonable considering the fees charged by other investment advisers offering similar services/programs.

You may also pay additional advisory fees to a third party money manager depending upon which manager you select. Our fees will not be based upon a share of capital gains or capital appreciation of the funds or any portion of your funds.

Your account at the custodian may also be charged for certain additional assets managed for you by us but not held by the custodian (i.e., mutual funds, 401(k)s).

The fees we charge can be deducted directly from your account at the custodian. We will instruct the custodian to deduct the fees from your account at the end of the quarter. This fee will show up as a deduction on your following monthly account statement from the custodian.

If you do not want us to charge your account for the fee, you may pay the fee directly to us. We will send you an invoice detailing the fee calculation. Fees are due in full 15 days after receipt of the invoice.

Financial Planning/Consulting Fees The following fee schedule applies for financial planning services:

Financial Planning/Consulting Fees Fee

Hourly Fee $300/hour

Fixed Project Fee $1,200 - $12,000

The fees shown above may be negotiable depending upon the nature and complexity of the client's circumstances. An estimate for total hours will be determined at the start of the advisory relationship. A deposit of 50% of the fee is due at the time the agreement is signed. The remainder of the fee is due upon presentation of an investment plan or the rendering of consulting services. Investment plans will be presented to you within 180 days of the contract date, provided that all information needed to prepare the investment plan has been promptly provided to us. If the financial plan is not delivered within 180 days, any unused portion of your deposit will be refunded to you. We do not accept prepayment of more than $500 in fees per client, six months or more in advance. The financial planning agreement will terminate once you receive the final plan.

The Financial Planning Agreement will show the fee you will pay.



If the plan is implemented through us, we may receive compensation from the sale of insurance products or advisory services recommended in the financial plan. This compensation would be in addition to the financial planning fee you pay. The fees and expenses you pay for the purchase of these products may be more or less than the expenses you would pay should you decide to implement our recommendations through another investment advisory firm or broker-dealer and are typically determined by the broker-dealer or investment company sponsoring the product. Therefore, a conflict of interest may exist between our interests and your interests since we may recommend products that pay us compensation. We may have an incentive to recommend particular products based upon the potential compensation rather than your needs. This potential conflict is addressed in our Code of Ethics.

Based upon your needs, we may also provide consultations throughout the year to advise and counsel you about other financial issues. We can help you with transition planning, major transaction analysis, coordinated with cash flow needs, retirement needs, estate planning needs, income tax planning, life and disability insurance needs, investment needs, and college education planning.

All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations.

Qualified Retirement Plan Advisory Fees Our standard fee includes establishing your Investment Policy Statement, reviewing your plan structure, investment management, investment selection and monitoring, fund changes, participant education and reporting. The fee will be outlined in your Advisory Agreement with us. Our typical fee schedule is as follows:

Percentage Plan Assets

Up to 2% All Plan Assets

Our fee is paid directly by the individual plan sponsors on a quarterly basis in arrears. The advisory agreement the plan sponsor has with us will outline exactly how the fees are charged and remitted to us.

You may also incur fees related to your use of outside service providers including third-party administrators and record keepers. The fee schedule for each outside service provider varies dramatically from service provider to service provider. The service provider’s fees will also vary from plan to plan as each plan’s structure and characteristics are different from the next.

We believe our services help plan sponsors and plan fiduciaries meet their fiduciary duty to the plan and its participants. As a part of our services, we review the fees of service providers and the transparency of their fees. We will assist the plan sponsors with a review of service providers including the third-party administrator, daily record keeper, and custodian to ensure that their services, along with ours, remain competitive to alternatives that are available.



Third Party Money Manager Fees Evidence Advisors will receive a third-party solicitor’s fee from CLS based on the product selected. This fee will be paid by CLS to Evidence Advisors out of the fee the Client pays to CLS.

If Betterment is selected to serve as the sub-advisor for the Client account, the Client will pay Betterment’s usual and customary fee for the services provided. The Client will also be charged a fee by Evidence Advisors that is in addition to the fee charged by Betterment. This fee ranges from 0.25% - 1.0% based upon the services provided by the Adviser.

Third Party Fees Our fees do not include brokerage commissions, transaction fees, and other related costs and expenses. You may incur certain charges imposed by custodians, third party investment companies and other third parties. These include fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds, money market funds and exchange-traded funds (ETFs) also charge internal management fees, which are disclosed in the fund’s prospectus. These fees may include, but are not limited to, a management fee, upfront sales charges, and other fund expenses. Certain strategies offered by us may involve investment in mutual funds and/or ETFs. Load and no load mutual funds may pay annual distribution charges, sometimes referred to as “12(b)(1) fees”. These 12(b)(1) fees come from fund assets, and thus indirectly from clients’ assets. We do not receive any compensation from these fees. All of these fees are in addition to the management fee you pay us. You should review all fees charged to fully understand the total amount of fees you will pay. Services similar to those offered by us may be available elsewhere for more or less than the amounts we charge. Our brokerage practices are discussed in more detail under Item 12 – Brokerage Practices.

Other Compensation Our IARs may recommend and sell life, disability, health, and long-term care insurance and will receive the usual and customary commissions in addition to any agreed upon advisory fee.

Wyatt Moerdyk may receive additional compensation from sales of insurance products. Wyatt Moerdyk may be eligible to receive incentive awards (including prizes such as trips or bonuses) for recommending certain types of insurance policies or other investment products that he recommends.

While Wyatt Moerdyk endeavors at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving incentive awards creates a conflict of interest, and may affect his judgment when making recommendations. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that Clients may purchase recommended insurance products from other insurance agents not affiliated with us.

Item 6 – Performance Based Fee and Side by Side Management

We do not charge any performance-based fees. These are fees based on a share of capital gains on or capital appreciation of the assets of a client.



Item 7 – Types of Client(s)

We provide asset management, financial planning, and financial consulting services to individuals, high net worth individuals, trusts, estates, corporate pension and profit-sharing plans, charitable organizations, foundations, endowments, corporations, small businesses and churches. We provide retirement plan services to qualified retirement plans.

We have no minimum account opening balance.

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

Methods of Analysis We use Fundamental Analysis, Technical Analysis, Cyclical Analysis, and Modern Portfolio Theory as part of our overall investment management discipline; the implementation of these analyses as part of our investment advisory services to you may include any, all or a combination of the following:

Fundamental Analysis Fundamental analysis is a technique that attempts to determine a security’s value by focusing on the underlying factors that affect a company's actual business and its future prospects. Fundamental analysis is about using real data to evaluate a security's value. It refers to the analysis of the economic well-being of a financial entity as opposed to only its price movements.

The end goal of performing fundamental analysis is to produce a value that we can compare with the security's current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short).

Modern Portfolio Theory (MPT) We use Modern Portfolio Theory to help select the funds we use in your account.

Modern portfolio theory tries to understand the market as a whole, rather than looking for what makes each investment opportunity unique. Investments are described statistically, in terms of their expected long-term return rate and their expected short-term volatility. The volatility is equated with "risk," measuring how much worse than average an investment's bad years are likely to be. The end goal is to identify your acceptable level of risk tolerance, and then to find a portfolio with the maximum expected return for that level of risk.

Technical Analysis Technical Analysis is a technique that attempts to determine a security’s value by developing models and trading rules based upon price and volume transformation. Technical analysis assumes that a market’s price reflects all relevant information so the analysis focuses on the history of a security’s trading behavior rather than external drivers such as economic, fundamental and news events. The practice of technical analysis incorporates the importance of understanding how market participants perceive and act upon relevant information rather than focusing on the information itself. Ultimately, technical analysts develop



trading models and rules by evaluating factors such as market trends, market participant behaviors, supply and demand and pricing patterns and correlations.

As with other types of analysis, the predictive nature of technical analysis can vary greatly; models and rules are often modified and updated as new patterns and behaviors develop. Past performance is not an indicator of future return.

Cyclical Analysis While we do not attempt to time the market, we may use cyclical analysis in conjunction with other strategies to help determine if shifts are required in your investment strategies depending upon long and short-term trends in financial markets and the performance of the overall national and global economy.

Investment Strategies In order to perform this analysis, we use many resources, such as:

• Morningstar, Fi360

• Financial newspapers and magazines (e.g. Wall Street Journal, Forbes, etc.)

• Annual reports, prospectuses, filings

• Company press releases and websites

The investment strategies we use to implement any investment advice given to you include, but are not limited to:

• Long term purchases -securities held at least a year

• Short term purchases - securities sold within a year

• Trading -securities sold within 30 days

• Short sales

• Margin Transactions

• Option writing, including covered options, uncovered options or spreading strategies.

Risk of Loss We cannot guarantee our analysis methods will yield a return. In fact, a loss of principal is always a risk. Investing in securities involves a risk of loss that you should be prepared to bear. You need to understand that investment decisions made for your account by us are subject to various market, currency, economic, political and business risks. The investment decisions we make for you will not always be profitable nor can we guarantee any level of performance.

A list of all risks associated with the strategies, products and methodology we offer are listed below:

Alternative Investment Risk Investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include:



• Loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices

• Lack of liquidity in that there may be no secondary market for the fund and none expected to develop

• Volatility of returns

• Absence of information regarding valuations and pricing

• Delays in tax reporting

• Less regulation and higher fees than mutual funds.

Bond Fund Risk Bond funds generally have higher risks than money market funds, largely because they typically pursue strategies aimed at producing higher yields of the risks associated with bond funds include:

• Call Risk - The possibility that falling interest rates will cause a bond issuer to redeem—or call—its high-yielding bond before the bond's maturity date.

• Credit Risk — the possibility that companies or other issuers whose bonds are owned by the fund may fail to pay their debts (including the debt owed to holders of their bonds). Credit risk is less of a factor for bond funds that invest in insured bonds or U.S. Treasury bonds. By contrast, those that invest in the bonds of companies with poor credit ratings generally will be subject to higher risk.

• Interest Rate Risk — the risk that the market value of the bonds will go down when interest rates go up. Because of this, you can lose money in any bond fund, including those that invest only in insured bonds or Treasury bonds.

• Prepayment Risk — the chance that a bond will be paid off early. For example, if interest rates fall, a bond issuer may decide to pay off (or "retire") its debt and issue new bonds that pay a lower rate. When this happens, the fund may not be able to reinvest the proceeds in an investment with as high a return or yield.

Fundamental Analysis Risk Fundamental analysis, when used in isolation, has a number of risks:

• There are an infinite number of factors that can affect the earnings of a company, and its stock price, over time. These can include economic, political and social factors, in addition to the various company statistics.

• The data used may be out of date.

• It is difficult to give appropriate weightings to the factors.

• It assumes that the analyst is competent.

• It ignores the influence of random events such as oil spills, product defects being exposed, and acts of God and so on.



Modern Portfolio Theory (MPT) Risk Modern Portfolio Theory tries to understand the market as a whole and measure market risk in an attempt to reduce the inherent risks of investing in the market. However, with every financial investment strategy there is a risk of a loss of principal. Not every investment decision will be profitable, and there can be no guarantee of any level of performance.

Cyclical Analysis Risk Looking at market cycles in conjunction with other investment strategies can be useful when making investment decisions. However, market cycles are not always predictable. Each financial investment strategy has benefits and risks. Not every investment decision will be profitable, and there can be no guarantee of any level of performance.

Exchange Traded Fund (“ETF”) Risk Most ETFs are passively managed investment companies whose shares are purchased and sold on a securities exchange. An ETF represents a portfolio of securities designed to track a particular market segment or index. ETFs are subject to the following risks that do not apply to conventional funds:

• The market price of the ETF’s shares may trade at a premium or a discount to their net asset value;

• An active trading market for an ETF’s shares may not develop or be maintained; and

• There is no assurance that the requirements of the exchange necessary to maintain the listing of an ETF will continue to be met or remain unchanged

Insurance Product Risk The rate of return on insurance products is not stable, but varies with the stock, bond and money market subaccounts that you choose as investment options. There is no guarantee that you will earn any return on your investment and there is a risk that you will lose money. Before you consider purchasing an insurance product, make sure you fully understand all of its terms. Some of the major risks include:

• Liquidity and Early Withdrawal Risk – There may be a surrender charges for withdrawals within a specified period, which can be as long as six to eight years. Any withdrawals before a client reaches the age of 59 ½ are generally subject to a 10 percent income tax penalty in addition to any gain being taxed as ordinary income.

• Sales and Surrender Charges – Asset-based sales charges or surrender charges. These charges normally decline and eventually are eliminated the longer you hold your shares. For example, a surrender charge could start at 7 percent in the first year and decline by 1 percent per year until it reaches zero.

• Fees and Expenses – There are a variety of fees and expenses which can reach 2% and more such as:

o Mortality and expense risk charges

o Administrative fees

o Underlying fund expenses



o Charges for any special features or riders.

• Bonus Credits – Some products offer bonus credits that can add a specified percentage to the amount invested ranging from 1 percent to 5 percent for each premium payment. Bonus credits, however, are usually not free. In order to fund them, insurance companies typically impose high mortality and expense charges and lengthy surrender charge periods.

• Guarantees – Insurance companies provide a number of specific guarantees. For example, they may guarantee a death benefit or an annuity payout option that can provide income for life. These guarantees are only as good as the insurance company that gives them.

• Market Risk – The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall.

• Principal Risk – The possibility that an investment will go down in value, or "lose money," from the original or invested amount.

Mutual Funds Risk The following is a list of some general risks associated with investing in mutual funds.

• Country Risk - The possibility that political events (a war, national elections), financial problems (rising inflation, government default), or natural disasters (an earthquake, a poor harvest) will weaken a country's economy and cause investments in that country to decline.

• Currency Risk -The possibility that returns could be reduced for Americans investing in foreign securities because of a rise in the value of the U.S. dollar against foreign currencies. Also called exchange-rate risk.

• Income Risk - The possibility that a fixed-income fund's dividends will decline as a result of falling overall interest rates.

• Industry Risk - The possibility that a group of stocks in a single industry will decline in price due to developments in that industry.

• Inflation Risk - The possibility that increases in the cost of living will reduce or eliminate a fund's real inflation-adjusted returns.

• Manager Risk -The possibility that an actively managed mutual fund's investment adviser will fail to execute the fund's investment strategy effectively resulting in the failure of stated objectives.

• Market Risk -The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall.

• Principal Risk -The possibility that an investment will go down in value, or "lose money," from the original or invested amount.



Stock Fund Risk Overall "market risk" poses the greatest potential danger for investors in stocks funds. Stock prices can fluctuate for a broad range of reasons, such as the overall strength of the economy or demand for particular products or services.

Technical Analysis risk • Technical analysis is derived from the study of market participant behavior and its efficacy is

a matter of controversy.

• Methods vary greatly and can be highly subjective; different technical analysts can sometimes make contradictory predictions from the same data.

• Models and rules can incur sufficiently high transaction costs.

Overall Risks Clients need to remember that past performance is no guarantee of future results. All funds carry some level of risk. You may lose some or all of the money you invest, including your principal, because the securities held by a fund goes up and down in value. Dividend or interest payments may also fluctuate, or stop completely, as market conditions change.

Before you invest, be sure to read a fund's prospectus and shareholder reports to learn about its investment strategy and the potential risks. Funds with higher rates of return may take risks that are beyond your comfort level and are inconsistent with your financial goals.

While past performance does not necessarily predict future returns, it can tell you how volatile (or stable) a fund has been over a period of time. Generally, the more volatile a fund, the higher the investment risk. If you'll need your money to meet a financial goal in the near-term, you probably can't afford the risk of investing in a fund with a volatile history because you will not have enough time to ride out any declines in the stock market.

Item 9 – Disciplinary Information

Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. We do not have any information to disclose concerning Evidence Advisors Investment Management or any of our IARs. We adhere to high ethical standards for all IARs and associates.

Item 10 – Other Financial Industry Activities and Affiliations

Neither Evidence Advisors Investment Management nor any of its management persons are registered as a broker-dealer or registered as a representative of a broker-dealer, nor does it have any pending application to register.



Other Financial Industry Affiliations Wyatt Moerdyk, the Managing Member and Chief Compliance Officer for Evidence Advisors Investment Management, is a licensed insurance agent/broker with various companies.

Wyatt Moerdyk may recommend insurance products and may also, as independent insurance agents, sell those recommended insurance products to clients. When such recommendations or sales are made, a conflict of interest exists as the insurance licensed IARs earn insurance commissions for the sale of those products, which may create an incentive to recommend such products. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that clients may purchase recommended insurance products from other insurance agents not affiliated with us. The sale of these products accounts for approximately 5% of his time.

Selection of Other Advisers Evidence Advisors Investment Management will be compensated by certain third party manager(s) from the advisory fees collected from the client. Details of these fees are/will be described in Item 5 – Fees and Compensation. This causes a conflict of interest in recommending certain third party managers since we may receive compensation for referring clients to these vendors. In order to mitigate this conflict of interest, we require all IARs to inform the client that they are under no obligation to implement any recommendations made by us or the third party manager.

Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading

General Information We have adopted a Code of Ethics for all supervised persons of the firm describing its high standards of business conduct, and fiduciary duty to you, our client. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts, the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All of our supervised persons must acknowledge the terms of the Code of Ethics annually, or as amended.

Participation or Interest in Client Accounts Our Compliance policies and procedures prohibit anyone associated with Evidence Advisors Investment Management from having an interest in a client account or participating in the profits of a client’s account without the approval of the CCO.

The following acts are prohibited:

• Employing any device, scheme or artifice to defraud

• Making any untrue statement of a material fact

• Omitting to state a material fact necessary in order to make a statement, in light of the circumstances under which it is made, not misleading



• Engaging in any fraudulent or deceitful act, practice or course of business

• Engaging in any manipulative practices

Clients and prospective clients may request a copy of the firm's Code of Ethics by contacting the CCO.

Personal Trading We may recommend securities to you that we will purchase for our own accounts. We may trade securities in our account that we have recommended to you as long as we place our orders after your orders. This policy is meant to prevent us from benefiting as a result of transactions placed on behalf of advisory accounts.

Certain affiliated accounts may trade in the same securities with your accounts on an aggregated basis when consistent with our obligation of best execution. When trades are aggregated, all parties will share the costs in proportion to their investment. We will retain records of the trade Order (specifying each participating account) and its allocation. Completed Orders will be allocated as specified in the initial trade order. Partially filled Orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order.

Evidence Advisors Investment Management has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of “Access Persons”. The policy requires that an Access Person of the firm provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide the Chief Compliance Officer or his/her designee with a written report of the Access Person’s current securities holdings at least once each twelve (12) month period thereafter on a date the Adviser selects; provided, however that at any time that the Adviser has only one Access Person, he or she shall not be required to submit any securities report described above.

We have established the following restrictions in order to ensure our fiduciary responsibilities regarding insider trading are met:

• No securities for our personal portfolio(s) shall be bought or sold where this decision is substantially derived, in whole or in part, from the role of IARs of Evidence Advisors Investment Management, unless the information is also available to the investing public on reasonable inquiry. In no case, shall we put our own interests ahead of yours.

Privacy Statement We are committed to safeguarding your confidential information and hold all personal information provided to us in the strictest confidence. These records include all personal information that we collect from you or receive from other firms in connection with any of the financial services they provide. We also require other firms with whom we deal with to restrict the use of your information. Our Privacy Policy is available upon request.



Conflicts of Interest Evidence Advisors Investment Management’s IARs may employ the same strategy for their personal investment accounts as it does for its clients. However, IARs may not place their orders in a way to benefit from the purchase or sale of a security.

We act in a fiduciary capacity. If a conflict of interest arises between us and you, we shall make every effort to resolve the conflict in your favor. Conflicts of interest may also arise in the allocation of investment opportunities among the accounts that we advise. We will seek to allocate investment opportunities according to what we believe is appropriate for each account. We strive to do what is equitable and in the best interests of all the accounts we advise.

Item 12 – Brokerage Practices

Factors Used to Select Custodians In recommending a custodian/broker-dealer, we look for a company that offers relatively low transaction fees, access to desired securities, trading platforms, and support services. We may recommend clients use Schwab as the qualified custodian for their accounts when utilizing our asset management services.

Soft Dollars Schwab and other third party managers may provide us with certain brokerage and research products and services that qualify as "brokerage or research services" under the rules. These research products and/or services will assist the IAR in its investment decision making process. Such research generally will be used to service all of the IAR’s clients, but brokerage commissions paid by the client may be used to pay for research that is not used in managing the client’s account. The account may pay to a broker-dealer a commission greater than another qualified broker-dealer might charge to effect the same transaction where the IAR determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received.

Because soft dollar benefits could be considered to provide a benefit to the adviser that might cause the client to pay more than the lowest available commission without receiving the most benefit, they are considered a conflict of interest in recommending or directing custodial and third party managerial services. Evidence Advisors mitigates these conflicts of interest through strong oversight of soft-dollar arrangements by the Chief Compliance Officer, in order to assure the soft dollar benefits serve the best interests of the client.

There may other benefits from recommending Schwab or other third party managers such as software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions, recordkeeping and client reporting.

Other services may include, but are not limited to, performance reporting, financial planning, contact management systems, third party research, publications, access to educational conferences, roundtables



and webinars, practice management resources, access to consultants and other third party service providers who provide a wide array of business related services and technology with whom Evidence Advisors may contract directly. Evidence Advisors may receive seminar expense reimbursements from product sponsors which may be based on the sales of products to their clients.

Soft dollar benefits may be proportionally allocated to any accounts that may generate different amounts of the soft dollar benefits.

Best Execution We have an obligation to seek best execution for you. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, reputation and responsiveness. Therefore, we will seek competitive commission rates, but we may not obtain the lowest possible commission rates for account transactions.

Brokerage for Client Referrals In selecting and/or recommending broker-dealers, we do not take into consideration whether or not we will receive client referrals from the broker-dealer or third party.

Directed Brokerage We recommend our clients use Schwab as the custodian for your account, however Clients are permitted to use the custodian of their choosing. Not all advisory firms permit you to direct brokerage. If you elect to select your own broker-dealer or custodian and direct us to use them, you may pay higher or lower fees than what is available through our relationships. Generally, we will not negotiate lower rates below the rates established by the executing broker-dealer or custodian for this type of directed brokerage account, unless we believe that such rate is unfair or unreasonable for the size and type of transaction. In all instances, we will seek best execution for you.

Trading Transactions for each client account generally will be effected independently, unless we decide to purchase or sell the same securities for several clients at approximately the same time. We may (but are not obligated to) combine or “batch” such Orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among our clients’ differences in prices and commission or other transaction costs. Under this procedure, transactions will be price-averaged and allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day.

Transactions placed in an asset management account by a third party manager will be executed through their broker-dealer or custodian. In determining best execution for these transactions, the third party manager is looking at whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. While they look for competitive commission rates, they may not obtain the lowest possible commission rates for account transactions. The aggregation and allocation practices of mutual funds and third party managers that we recommend to



you are disclosed in the respective mutual fund prospectuses and third party manager disclosure documents which will be provided to you.

Qualified Retirement Plan Trading We do not accept trading authorization with respect to any participants’ plan account.

Item 13 – Review of Accounts

Reviews Reviews are conducted at least annually or as agreed to by us. Reviews will be conducted by our Chief Compliance Officer and Managing Member Wyatt Moerdyk. You may request more frequent reviews and may set thresholds for triggering events that would cause a review to take place. Generally, we will monitor for changes and shifts in the economy, changes to the management and structure of a mutual fund or company in which client assets are invested, and market shifts and corrections.

Reports You will be provided with account statements reflecting the transactions occurring in the account on at least a quarterly basis. These statements will be written or electronic depending upon what you selected when you opened the account. You will be provided with paper confirmations for each securities transaction executed in the account. You are obligated to notify us of any discrepancies in the account(s) or any concerns you have about the account(s).

Item 14 – Client Referrals and Other Compensation

We do not directly or indirectly pay any compensation to another person if they refer clients to us.

We may receive economic benefit from someone who is not a client for providing investment advice or other advisory services to our clients. Evidence Advisors Investment Management will be compensated by the third party manager(s) from the advisory fees collected from the client. This may cause a conflict of interest in recommending certain third party managers since we may receive compensation for referring clients to these vendors. In order to mitigate this conflict of interest, we require all IARs to inform the client that they are under no obligation to implement any recommendations made by us or the third party manager.

Item 15 – Custody

Asset Management We do not have physical custody of any accounts or assets. However, we may be deemed to have constructive custody of your account(s) since we have the ability to deduct your advisory fees from the



custodian. We use Schwab as the custodian and/or broker-dealer for your accounts. You should receive at least quarterly statements from the broker-dealer or custodian that holds and maintains your investment assets. We urge you to carefully review such statements.

We do not debit the client fees directly from your advisory account. We send information to your custodian to debit your fees from your account and to pay them directly to us. You authorized the custodian to pay us directly at the onset of the relationship.

Qualified Retirement Plan Custody We do not have actual or constructive custody of any client’s account. We do not have the ability to deduct fees directly from the plan accounts.

Item 16 – Investment Discretion

Asset Management We usually receive discretionary authority from you at the beginning of an advisory relationship to select the identity and amount of securities to be bought or sold. This information is described in the Advisory Agreement you sign with us. In all cases, however, this discretion is exercised in a manner consistent with your stated investment objectives for your account.

When selecting securities and determining amounts, we observe the investment policies, limitations and restrictions you have set. For registered investment companies, our authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made.

Prior to assuming discretionary authority, clients must execute the Advisory Agreement. Execution of the Advisory Agreement grants us the authority to determine, without obtaining specific client consent, both the amount and the type of securities to be bought and sold to help achieve the client account objectives.

The third party money manager and/or custodians may have discretion over your account. The Advisory Agreement details this in full.

Qualified Retirement Plan We usually receive discretionary authority for 3(38) qualified retirement plan advisory services at the beginning of the relationship through the execution of a limited power of attorney to have the authority to determine and select securities that are in the plan. However, individual plan participants have the responsibility to determine the amount of securities bought and sold in their individual plan accounts.

Our recommendations regarding our 3(21) qualified retirement plan consulting services are made on a non-discretionary basis. The plan sponsor retains the decision making authority over the plan. When recommending securities, we observe the investment policies, limitations, and restriction set by the plan and plan sponsor.



Item 17 – Voting Client Securities

As a matter of firm policy and practice, we do not have any authority to and do not vote proxies on behalf of advisory clients. You retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolios. We may provide advice to you regarding your voting of proxies. The custodian will forward you copies of all proxies and shareholder communications relating to your account assets.

Item 18 – Financial Information

We are required to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that would impair our ability to meet any contractual and fiduciary commitments to you, our client. We have not been the subject of any bankruptcy proceedings. In no event shall we charge advisory fees that are both in excess of five hundred dollars and more than six months in advance of advisory services rendered.

Item 19 – Requirements for State Registered Advisers

Principals There is one principal of Evidence Advisors Investment Management, Wyatt Moerdyk. He is the CCO and Managing Member and was born in 1972. His education information, business background, and other business activities can be found in the Form ADV Part 2B Brochure Supplement below.

Performance Fees We do not charge a performance-based fee (fees based on a share of capital gains on, or capital appreciation of, the assets of a client) for our normal asset management accounts.

Disclosable Events Neither Evidence Advisors Investment Management nor Wyatt Moerdyk has no reportable events to disclose here.

Other Relationships Neither Evidence Advisors Investment Management nor Wyatt Moerdyk has any relationship with any issuer of securities.

Evidence Advisors ADV Part 2B April 2016 of 28


ADV Part 2B Brochure Supplement – Wyatt Moerdyk, AIF®

Item 1 – Cover Page

Wyatt Moerdyk, AIF®

CRD # 4644751

Evidence Advisors, LLC 10004 Johns Road

Boerne, TX 78006

Phone: (210) 710-0691 www.evidenceadvisors.com April 15, 2016

This Brochure supplement provides information about Wyatt Moerdyk and supplements the Evidence Advisors (“Evidence Advisors Investment Management”) Brochure. You should have received a copy of that Brochure. Please contact Wyatt Moerdyck if you did not receive the Brochure or if you have any questions about the contents of this supplement.

Additional information about Wyatt Moerdyk is available on the SEC’s website at www.adviserinfo.sec.gov.

http://www.evidenceadvisors.com/

http://www.adviserinfo.sec.gov/



Item 2 – Educational Background and Business Experience Full Legal Name: Wyatt A. Moerdyk Year of Birth: 1972

Education

Bachelor of Education 1996 Master of Music 1998 Michigan State University, East Lansing, MI

Designations AIF® 2015 Center for Fiduciary Studies, Bridgeville, PA

Accredited Investment Fiduciary (AIF)

Designation Accredited Investment Fiduciary

Designation Status Currently offered and recognized by the issuing organization

Acronym AIF

Issuing Organization Center for Fiduciary Studies

Prerequisites/Experience Required

Candidate must meet a point-based threshold based on a combination of education, relevant industry experience and/or professional development.

Educational Requirements Candidate must complete one of the following:

• Web-based program

• Capstone program

Examination Type Final certification exam, proctored closed book

Continuing Education/Experience Requirements 6 hours per year

Business History

April 2016 – Present CCO and Managing Member at Evidence Advisors Investment Management

January 2013 – April 2016 Registered Rep. and Investment Adviser Rep. at Cetera Advisor Networks LLC

February 2010 – December 2012 Registered Representative at Financial Network

August 1998 – December 2012 Teacher at North East ISD

July 2008 – February 2010 Registered Representative at Lincoln Financial Securities Corporation

April 2004 – June 2008 Registered Representative at Jefferson Pilot Securities



Item 3 – Disciplinary History Neither Evidence Advisors Investment Management nor Wyatt Moerdyk has any disciplinary history to disclose.

Item 4 – Other Business Activities Wyatt Moerdyk, the Managing Member and Chief Compliance Officer for Evidence Advisors Investment Management, is a licensed insurance agent/broker with various companies.

Wyatt Moerdyk may recommend insurance products and may also, as independent insurance agents, sell those recommended insurance products to clients. When such recommendations or sales are made, a conflict of interest exists as the insurance licensed IARs earn insurance commissions for the sale of those products, which may create an incentive to recommend such products. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that clients may purchase recommended insurance products from other insurance agents not affiliated with us. The sale of these products accounts for approximately 5% of his time.

Item 5 – Additional Compensation Wyatt Moerdyk may receive additional compensation from sales of insurance products. Wyatt Moerdyk may be eligible to receive incentive awards (including prizes such as trips or bonuses) for recommending certain types of insurance policies or other investment products that he recommends.

While Wyatt Moerdyk endeavors at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving incentive awards creates a conflict of interest, and may affect his judgment when making recommendations. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that clients may purchase recommended insurance products from other insurance agents not affiliated with us.

Item 6 – Supervision Wyatt Moerdyk is the CCO and Managing Member and performs all supervisory duties for his firm.

Item 7 – Requirements for State-Registered Advisers Wyatt Moerdyk has no reportable events to disclose here.

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